Assessment u/s 153A cannot be made on same set of material available during original assessment proceedings

Roseberry Mercantile Pvt. Ltd. Vs ACIT (ITAT Delhi)

Conclusion:

While on search nothing adverse was found so as to prove that documents filed during original assessment proceedings were false or untrue, AO on same set of material could not take a different view than already taken at the time of original assessment merely because a search had taken place.

Held:

Original assessment was completed u/s 147/143(3). A s

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